The old tax has not been cleared and the new tax is coming, 330,000 importers are caught in a long wait, when will you get your money back?

As the year 2026 began, U.S. tariff policy was thrown into an unprecedented mess of "old and new".

In February, the U.S. Supreme Court ruled that tariffs previously imposed by the government under the International Emergency Economic Powers Act (IEEPA) were unlawful impositions involving up to$175 billionof customs duties need to be refunded. More than 330,000 importers were energized by the news - the money was finally coming back.

However, before the rebate could hit the ground, the government turned around and invoked Section 122 of the Trade Act of 1974, announcing a temporary tariff of 101 TP3T on global goods, which was later raised to 151 TP3T.

Old debts not yet settled, new ones added--This is the real dilemma faced by all the current export enterprises to the United States. Today, an article to give you a thorough: when will the tax rebate in the end? The new tariffs and what is the situation? How to deal with foreign trade enterprises?

I. Tax refund mess: $175 billion, where's the money?

How much money is involved?

According to documents filed with the court by U.S. Customs and Border Protection (CBP), as of March 2026, more than 330,000 importers had cumulatively declared more than 53 million imported goods to CBP, paying IEEPA duties totaling up to about$166 billion to $182 billion.. This is the largest tariff rollback in U.S. history, bar none.

How are the tax refunds coming along?

The good news is: tax refunds are on the way. The bad news is:It's a long road.

CBP admits that system, process, and manpower constraints mean that large-scale tax refunds won't be available untilGradual roll-out only at the end of April. And TD Securities Inc. expects thatIt takes 12 to 18 months for refunds to actually reach the accountThe

What does this mean? You've paid your customs duty and it's "draining" your cash flow, but your refund is nowhere in sight. For small and medium-sized enterprises (SMEs), this financial squeeze can be fatal.

Why so slow?

CBP explained in detail the six major technical obstacles faced by the existing system in processing IEEPA duty refunds: IEEPA duty is not listed as a separate tax item in most import records, making it difficult to identify; the system's batch processing capacity is limited and error-prone; a large number of interest calculations still need to be done manually; each refund is subject to a double-certification process; a vast majority of importers have not yet activated the e-refund acceptance function; and redeployment of manpower to process refunds would seriously affect other normal CBP operations. The majority of importers have not yet activated the function of receiving electronic tax refunds; and the manpower deployed to process tax refunds will seriously affect other normal work of CBP.

Can businesses only wait?

Not necessarily. There are alreadyMore than 1,800 businesses have filed lawsuits, recovering tax refunds through legal means. However, the litigation period is equally long and costly.

There is one more key detail: CBP has clarified that all tax refunds must be issued electronically. But as of early March, of the 330,000 eligible importers, only about21,200 homesCompleted enrollment in the e-refund system accounts for less than 101 TP3T. i.e., a large number of people who would have been eligible to receive the money won't be able to receive it when the system opens because their accounts aren't set up.

II. New tariff "filler": old rules rejected, new rules in place

Switching Legal Tools: From IEEPA to Article 122

After the Supreme Court struck down the IEEPA tariffs, the government quickly invoked another law, Section 122 of the Trade Act of 1974. This provision allows the President to temporarily impose tariffs of up to 151 TP3T for up to 150 days in response to a balance of payments deficit or trade shock.

So here comes a new round of global tariffs: first 101 TP3T, then raised to 151 TP3T.

pivotal point in time

Under article 122, such "global import tariffs" can only be maintained for a maximum period of time.150 days, unless Congress grants an extension. This means that if Congress does not intervene, these new tariffs will automatically expire in the second half of 2026.

Any more moves to follow?

The government is also looking at other legal tools, includingReopening of the 301 investigation(on intellectual property and technology transfer in China) and232 Investigations(national security implications of product-specific imports). This means that even if section 122 tariffs expire, other forms of tariffs may "take their place".

If you still have questions about the U.S. tariff rebate or new tariff policy, or need to handle the U.S. company registration, EIN application services, welcome to contact me at any time (micro-signal: qcygscszk, or call my cell phone: 18676749275). Let us help you find certainty in the midst of policy chaos with our professional U.S. market services experience.

Third, to the foreign trade enterprises: policy changeable, how should you respond?

Takeaway #1: Don't bet on a single market, single rule

From IEEPA to Section 122, from rebates to new duties, U.S. tariff policy has flipped several times in just a few months. If you put all your eggs in one basket, the U.S., the risks can be imagined.

Takeaway 2: Exports to the U.S. Need to Set Aside Tariff Costs

The new tariffs have landed and may be adjusted at any time. It is recommended to leave enough buffer space for tariffs when quoting and calculating profits. Do not calculate according to the "best case scenario", but according to the "worst case scenario".

Takeaway 3: Pay close attention to the launch of tax refunds at the end of April

CBP has indicated that the tax refund process will start gradually at the end of April. It is recommended to complete the registration of the e-tax refund system in advance and pay close attention to the CBP notice. If your import record is attached to the name of a freight forwarder or a third party, it is recommended to confirm the contractual agreement in advance to ensure that the tax refund will be channeled to you.

Insight 4: Consider U.S. localization layout

Both the new IOR regulations and the tariff policy point to the same trend:Only companies with a real physical presence in the U.S. can enjoy the dividends of stable access to the U.S. market. Incorporating a U.S. company, applying for an EIN, purchasing a Bond, completing a CBP filing - these are no longer "optional", they are "mandatory".

Fourth, the enterprise financial surplus can do for you what

In the face of the chaos of the U.S. tariff policy "old and new", you need not only a provider of information, but a truly understand the U.S. market, can help you land compliance professional partners.

The value that Enterprise Finance earnings can bring to you:

Let's you quickly figure out exactly how tax refunds and new taxes affect you.
We'll help you analyze your rebate expectations and tariff costs based on your import records, cooperation patterns, and tell you what money you'll get back and what costs to account for.

Getting you through the U.S. company registration and compliance process.
If you are considering avoiding the risk of tariff fluctuations through a U.S.-based entity, we can provide you with a complete solution from incorporation, EIN application to CBP filing. We have a branch office in the U.S. and are familiar with local regulations and hands-on processes.

Lets you build trade systems that can cope with policy fluctuations.
From supply chain diversification to market diversification, from tariff set-aside to exchange rate hedging, we'll help you sort out a trade system that can cope with policy fluctuations, so you're no longer on the receiving end.

Gives you a ready-to-use local U.S. backup.
When you encounter tax refund issues, duty disputes, or even tax audits in the U.S. market, our local U.S. team can respond in a timely manner to give you professional guidance and support.

If you still have questions about the U.S. tariff rebate or new tariff policy, or need to handle the U.S. company registration, EIN application services, welcome to contact me at any time (micro-signal: qcygscszk, or call my cell phone: 18676749275). Let us help you find certainty in the midst of policy chaos with our professional U.S. market services experience.